After regulatory arbitrage is over, how can leading exchanges compete for the “gold content” of license licenses?

By Chloe, ChainCatcher
Original title: The era of regulatory arbitrage has come to an end, and there is a big competition for the amount of money in crypto exchange licenses
Over the past decade, the expansion logic of cryptocurrency exchanges has been to “buy users first, then talk about compliance.” However, this logic was completely reversed in 2026, and now, what can really close the gap is the compliance dividend brought by the license.
When the era of regulatory arbitrage comes to an end, how can Binance, OKX, Bitget, Bybit, and Gate use very different strategies to compete for entry into the next round of patterns?
2026 A New Battleground Among Exchanges: Compliance Dividends
According to the annual derivatives market report released by CoinGlass in 2025, the total trading volume of derivatives on centralized exchanges reached 85.7 trillion US dollars throughout the year, an average of about 264.5 billion US dollars per day, and the market share is highly concentrated, with the top five exchanges accounting for more than 80% of open positions. With such a market size, if any leading exchange wants to continue to grow, it is no longer possible to differentiate by simply “lower fees” or “more currencies” because the marginal utility of these advantages is shrinking.
The market position and current ranking of the five exchanges
Before we go into the license inventory, let's use the data to see the relative positions of these five exchanges in 2026.
According to the TokenInsight 2025 report, the annual spot market share distribution is as follows: Binance 42.09%, Bybit 8.63%, MEXC 8.49%, Gate 8.16%, Bitget 6.86%, OKX 6.83%, Coinbase 6.58%, KuCoin 4.31%

The pattern of the derivatives market is slightly different. Data shows that in 2025, Binance ranked first with an average market share of 34.74%, OKX ranked second with 15.06%, Bybit ranked third with 12.95%, Bitget ranked fourth with 11.27%, and MEXC and Gate were 10.58% and 8.25%, respectively.

These two sets of data show that apart from Binance's absolute advantage in the spot and derivatives markets, the shares of the other four companies are actually tied together. As the size of the market expands and share distribution stabilizes, anyone who can get a license for a key market will have a chance to jump one step higher in the next round of reshuffle.
Notably, these five leading exchanges also maintain leading positions in terms of compliance transparency. According to the crypto asset data platform RootData, Binance, OKX, Bybit, Gate, and Bitget continued to rank in the top five in the 8th “Cryptocurrency Exchange Transparency List (Stock Category)” published by the Web3 asset data platform RootData, which is highly consistent with the pattern of spot and derivatives market share. The list continues to focus on the growing trend of stock assets on crypto exchanges.

Binance: The absolute leader's shift to compliance
Binance is the only player on this list that doesn't need to worry about market share, but it is the one that is under the most regulatory pressure.
Between 2023 and 2024, Binance faced a series of major regulatory fines and settlements in the US and many countries, which fundamentally changed the company's strategy. According to Nikkei Asia, Binance Asia Pacific Head SB Seker said in March 2026 that Binance plans to obtain five new licenses in Asia within 2026, boosting the number of licensed jurisdictions worldwide to more than 20.
As of the beginning of 2026, Binance already holds regulatory approvals from Australia, India, Indonesia, Japan, New Zealand, and Thailand in Asia. Through the acquisition of a controlling interest in South Korea's Gopax, the Korean license will soon enter the market.
Binance's global scale itself is creating a compliance narrative. According to Binance's 2025 report, Binance Global has more than 300 million registered users, and spot trading volume for the full year of 2025 exceeds $7.1 trillion. At this level, Binance was banned in any single country, affecting not only local users, but also the entire OTC market and stablecoin liquidity. Among them, Binance's licensing strategy is not the same as other exchanges. In many markets, it obtains a license by acquiring a local licensed entity (such as Gopax) rather than applying from scratch. This approach can shorten the time period, but it also means that Binance must take on the historical burden of the acquired party.
Binance's 2025 compliance narrative data will be directly updated in its compliance update report. Direct and indirect capital flows related to sanctions fell 96.8% from 0.284% of total transaction volume in January 2024 to 0.009% in July 2025.

Bitget: the latecomer who piled up licenses from scratch
Bitget is the last of these five exchanges to start issuing licenses, but the speed and breadth of license stores is quite active. According to an open letter published by Bitget in April 2025, it was signed by Chief Legal Officer Hon Ng, when Bitget had obtained “more than 8 licenses.” By early 2026, Bitget has regulatory registrations in Europe, Asia, the Middle East, Latin America, and Oceania, including Australia, Italy, Poland, El Salvador, the United Kingdom, Bulgaria, Lithuania, the Czech Republic, Georgia, and Argentina.
On the Asian side, Bitget completed registration with VARA (Dubai Virtual Asset Supervisory Authority) at the end of 2025, authorized it to provide regulated virtual asset services from its Dubai headquarters, also obtained a digital asset license in Georgia, and used the Tbilisi Free Zone as a base for expansion in Eastern Europe.
Judging from the license strategy, Bitget follows the “breadth first, depth later” route. It mostly obtained VASP registrations in Europe rather than full MiCA CASP licenses; in Asia, it has yet to obtain full licenses for the three markets with the highest gold content, Japan, Hong Kong, and Singapore. Perhaps the challenge for Bitget is that once the number of licenses reaches a certain scale, the market will start questioning “quality.”
Bybit: Fluctuating between setbacks and breakthroughs
Bybit has the most tortuous license path among these five. In May 2024, Bybit withdrew from the Hong Kong market due to regulatory pressure from the Hong Kong Securities Regulatory Commission, and its associated entity, Spark Fintech Limited, officially withdrew its license application. By the end of 2025, Bybit announced that it will phase out services for Japanese residents in 2026 and require affected users to complete identity verification by January 22, 2026, otherwise they will be considered Japanese residents and restricted from use. On the Singapore side, the Monetary Authority of Singapore MAS requires unlicensed digital token service providers to stop operating overseas by June 2025, and Bybit also ceases operations in Singapore.
But at the other end of the day, Bybit won two relatively high-value licenses in the industry. In October 2025, the UAE Securities and Commodities Authority SCA granted Bybit the first complete “Virtual Asset Platform Operator License”, covering trading, brokerage, escrow and fiat services in seven emirates throughout the UAE. In Europe, Bybit EU GmbH obtained a MiCAR license through the Austrian Monetary Authority FMA in May 2025, and can travel in 29 countries of the European Economic Area.

Additionally, Bybit suffered the largest hacking attack in crypto history in February 2025, and lost approximately $1.46 billion. This incident put a lot of pressure on Bybit's compliance and security narrative in 2025, and was one of the triggering events for the Japan Financial Services Agency to consider requiring exchanges to accrue capital reserves. Bybit's case illustrates one thing: “having a license” and “being able to hold a license for a long time” are two different things.
Gate: A compliance matrix quietly piled up
Gate's visibility in the Asian Chinese community isn't as good as Binance and OKX, but if you just look at the details of license plate coverage, Gate's layout is surprisingly complete. According to the license page published by Gate, Gate obtained regulatory registrations, licences or approvals in more than eight jurisdictions in early 2026, including Hong Kong, Gibraltar, Malta, Japan, Australia, the Bahamas, the DMCC in Dubai, and Cyprus.
In terms of regulatory coverage, Gate's strategy is closer to “establishing separate entities and obtaining individual licenses in every key jurisdiction” rather than “using one headquarters license to travel across multiple countries.” This approach is more expensive, but it is also relatively more resistant to regulatory risks. For example, in Europe, Gate has both Lithuania's VASP registration (for use in the early EU) and Malta's MiCA license (a pass under the new framework), which is double insured.
On the other hand, Gate's share growth in the Asian derivatives market is particularly noteworthy. According to TokenInsight data, Gate's OI market share in 2025 grew from 4.15% at the beginning of the year to 14.11% at the end of the year; the speed of license issuance is highly synchronized with the rate of market share growth.

OKX: Compliance restart in exchange for settlement
OKX's licensing path underwent a complete restart in 2025. In April 2025, OKX reached a settlement with the US Department of Justice, paid approximately $505 million in fines, and officially resumed operations in the US, with headquarters in San Jose, California. As of early 2026, OKX holds currency converter licenses in more than 40 states in the US and is registered as a money services business with FinCEN.

On the Asian side, OKX's license distribution is as follows:
Singapore: OKX SG Pte. Ltd. obtained the full MAS Major Payment Institution (MPI) license from the Monetary Authority of Singapore in 2024 and hired former MAS official Gracie Lin as CEO of Singapore. This license is recognized as having a high gold content in Asia because of the strict audit standards of the Singapore MAS and the slow pace of licensing.
DUBAI: OKX holds a VASP license at VARA and was one of the first international exchanges to sign an MOU with VARA and obtain a temporary license.
Europe: Based in Malta, OKCoin Europe Ltd obtained a MiCA license in January 2025 and is one of the first global exchanges to obtain a full MiCA CASP license.
Australia: OKX Australia Pty Ltd is registered with the Australian Securities and Investments Commission ASIC.
However, OKX also has a clear licensing gap. On the Hong Kong side, OKX has withdrawn its VATP license application, and on the Japanese side, OKX is still on the OKX restricted service list as of the beginning of 2026. In other words, OKX's high-value licenses in Asia are concentrated in Singapore and Dubai, but the two markets of Japan and Hong Kong have yet to be opened.
Its license narrative is probably “paying a price to re-enter the US and using this price in exchange for the trust of global institutions.”
Why do some license plates have “no gold content”?
Based on verifiable regulatory documents and practical experience in the industry, cryptographic licenses can be roughly divided into three layers.
Level 1: High Gold License
The characteristics of this type of license are that the licensing authority is in the mainstream financial supervision system. The application process is lengthy, capital and governance requirements are high, it can carry out complete retail business, and can connect local banks and fiat channels.
Representative cases include:
Full MPI license for MAS in Singapore (held by OKX SG). According to Bloomberg, Singapore will only issue 13 crypto licenses in total in 2024.
Hong Kong SFC's Type 1 and Type 7 licenses. As of the end of 2024, there were 7 fully licensed virtual asset trading platforms in Hong Kong (4 of which obtained restricted licenses on December 18), and 7 others have temporary licenses.
Cryptocurrency trader registration with Japan's FSA. VASP full operating license for VARA in Dubai.
UAE SCA's full virtual asset platform operator license (Bybit is the first).
EU MiCA full CASP license.
Second tier: medium gold license
The characteristics of this type of license are: they can operate legally, but the scope of business is limited, or the regulatory framework in the jurisdiction where they are located is still under construction, or the local financial system is small.
Representative examples: VASP registrations in EU member states such as Lithuania, Italy, and Poland (held by many exchanges, but usually only an expedient option during the MiCA transition period), Salvadoran BSP and DASP licenses, Georgian digital asset licenses, and Bulgarian VASP licenses.
These licences themselves are legal and authentic, but they are relatively easy to obtain, so holding them alone is unlikely to create a competitive threshold.
Level 3: Low Gold License
The characteristic of this type of license is that the issuing authority may be the financial department of a small country, a commercial registration authority, or a free trade zone administrator. Licensing standards may only require basic KYC/AML processes, and licensees may not have any rights to fiat bank access or local retail operations. Judging from trustworthiness and signal value, this type of license is closer to a kind of “company registration” rather than a “financial license.”
After grading, if you look back at the license performance of the five exchanges, you'll get a clearer picture:
Binance has obtained six high-gold licenses in Asia (including seven for the upcoming purchase of Gopax), which is its absolute moat.
OKX is available in the three high-gold regions of Singapore, Dubai, and the European Union, but Japan and Hong Kong are absent.
It won the full UAE license and MiCAR, but it was blocked at the same time in Japan, Hong Kong, and Singapore, showing a “polarized” pattern.
Gate entered Japan through an acquisition and obtained a MiCA license in Malta, plus a complete operating license for VARA in Dubai, and has three footholds in the high gold content range.
Bitget is currently the weakest in the high gold content range, and the “breadth” of low to medium gold content licenses is still the main story.
The next phase of the compliance license competition
From the trajectory of these five exchanges, several clear rules can be summarized.
The era of regulatory arbitrage is over
In the past, exchanges could register in the Seychelles or the British Virgin Islands and serve global users through a decentralized operating structure; this path was essentially blocked in 2025. The European Union's MiCA, Singapore's DTSP system, Hong Kong's VATP framework, and Japan's FSA system all require exchanges to have local entities, licenses, compliance officers, and capital reserves.
“Acquiring a licensed entity” is more efficient than “reapplying”
Binance's acquisition of Gopax into Korea, Gate's acquisition of Coin Master into Japan, Bybit's negotiation to acquire Korbit, and Binance's acquisition of Sakura Exchange BitCoin into Japan are all based on this logic. For regulators in mature markets (Japan, South Korea), issuing a new license requires lengthy review; however, allowing existing licensees to change the shareholder structure is a more viable path.
It was fined by regulation, but instead became a compliance certification
OKX officially entered the US after paying a $505 million settlement, and Bybit's Indian subsidiary obtained FIU-IND registration after paying a fine of about $1.06 million. They all showed a counterintuitive phenomenon: in the crypto industry, they had assumed regulatory penalties and completed settlements, but were instead viewed as proof of “whitewashing.” Because past problems have been “priced,” this can be seen as good news that they have run out of steam.
The number of license plates will be a key indicator for measuring the value of an enterprise
In the past, the criteria for evaluating exchanges were trading volume, number of users, and number of coins. In the future, an item will be added to this list: “Number of High Gold Content Licenses.” Judging from recent mergers and acquisitions and financing valuations in the industry, this indicator has already begun to influence pricing.
Conclusion: Compliance is not the end; it is a new starting line
In the past, the industry often said “compliance is a cost.” But the data from 2025 to 2026 clearly shows that compliance is also revenue.
According to CoinGecko data, the total spot trading volume of the top ten centralized exchanges before 2025 was about 18.7 trillion US dollars, an annual increase of 7.6%. In this total growth, the contribution of regulated markets (European MiCA, Singapore, Dubai, Japan) is significantly higher than that of unregulated markets. In other words, the growth rate of the compliance market has surpassed the growth rate of the grey market.
What this means for the five exchanges is that whoever obtains a full Japanese license from 2026 to 2027, who passes the review by a third party on the Hong Kong VATP list, who can be considered a “qualified counterparty” by the European Bank under the MiCA framework, and who can pass the Singapore MAS institutional business review will have a chance to step up again in the next round of the pattern.
For users and investors, understanding the true value of a license, rather than simply seeing the advertisement of “holding an XX license”, is the basis for judging the long-term sustainability of an exchange.
A license plate is not a panacea. In February 2025, while holding multiple licenses, Bybit still suffered a $1.46 billion hacker attack; in 2024, the Hong Kong JPEX and HOUNAX scandal caused more than $172 million in losses. A license can reduce regulatory risk, but it cannot eliminate the impact of individual events.
However, between exchanges with licenses, reserves, independent escrow, and regular audits, and exchanges without these, the marginal security gap will widen with every Black Swan incident.
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